Welcome To Your CDP Water Security Questionnaire 2019 W0 .

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FirstEnergy Corporation CDP Water Security Questionnaire 2019 Wednesday,July 31, 2019Welcome to your CDP Water Security Questionnaire2019W0. IntroductionW0.1(W0.1) Give a general description of and introduction to your organization.Headquartered in Akron, Ohio, FirstEnergy (FE) is a forward-thinking electric utility powered bya diverse team of employees committed to making customers' lives brighter, the environmentbetter and communities stronger. Our subsidiaries are involved in the transmission, distribution,and regulated generation of electricity.Our workforce of approximately 12,500 employees is dedicated to safety, reliability andoperational excellence. Our 10 electric distribution companies form one of the nation’s largestinvestor-owned electric systems, based on serving 6 million customers in Ohio, Pennsylvania,New Jersey, West Virginia, Maryland and New York. The company’s transmission subsidiariesoperate approximately 25,000 miles of transmission lines connecting the Midwest and MidAtlantic regions.On March 31, 2018, the Board of Directors of FirstEnergy Solutions (FES) FirstEnergy’scompetitive generation segment made a voluntary filing under Chapter 11 of the United StatesBankruptcy Code for FES, its subsidiaries and FirstEnergy Nuclear Operating Company(FENOC), to facilitate an orderly financial restructuring. The filing did not involve FirstEnergy orour Distribution, Transmission, Regulated Generation or Allegheny Energy Supply (AE Supply)subsidiaries. On September 25, 2018, the bankruptcy court approved a definitive agreement,subject to various conditions, that addressed FirstEnergy’s obligations with respect to FES andFENOC. Upon emergence, FES will be a separate company unaffiliated with FE and we willno longer report their data.For the purposes of this CDP report, all financial and emissions information is based onFirstEnergy's 2018 year-end portfolio.This report contains forward looking statements based on information available to thecompany. For more information, including our full forward looking statement pleasevisit: estor/engagement.htmlW-EU0.1a(W-EU0.1a) Which activities in the electric utilities sector does your organizationengage in?Electricity generationTransmission1

FirstEnergy Corporation CDP Water Security Questionnaire 2019 Wednesday,July 31, 2019DistributionW-EU0.1b(W-EU0.1b) For your electricity generation activities, provide details of yournameplate capacity and the generation for each power source.Nameplate capacity(MW)% of total nameplatecapacityGross generation(MWh)Coal – s5453.5545,184.9Biomass000Waste er renewable000Other nonrenewable000Total15,33210072,422,411W0.2(W0.2) State the start and end date of the year for which you are reporting data.Reporting yearStart dateEnd dateJanuary 1, 2018December 31, 2018W0.3(W0.3) Select the countries/regions for which you will be supplying data.United States of AmericaW0.4(W0.4) Select the currency used for all financial information disclosed throughoutyour response.USD2

FirstEnergy Corporation CDP Water Security Questionnaire 2019 Wednesday,July 31, 2019W0.5(W0.5) Select the option that best describes the reporting boundary for companies,entities, or groups for which water impacts on your business are being reported.Companies, entities or groups over which operational control is exercisedW0.6(W0.6) Within this boundary, are there any geographies, facilities, water aspects, orother exclusions from your disclosure?YesW0.6a(W0.6a) Please report the exclusions.ExclusionPlease explainCorporate, and energydelivery associated facilities.Water is essential to FirstEnergy's ability to generate electricity,therefore only the generation fleet is included in this disclosure.W1. Current stateW1.1(W1.1) Rate the importance (current and future) of water quality and water quantity tothe success of your business.Direct useimportanceratingIndirect useimportanceratingPlease explainSufficientVitalamounts of goodquality freshwateravailable for useImportantDirect water is essential to FirstEnergy's ability togenerate electricity, all of our plants use water forsteam production, material delivery, and plantcooling purposes. This is evidenced by our totalwithdrawal averaging almost 3,600 mega liters ofwater per day. Indirect: Municipal Water supply isimportant to support many of our WASHoperations for our employeesSufficientImportantamounts ofrecycled, brackishand/or producedwater availablefor useNeutralOf the 9 generation facilities operated byFirstEnergy in 2018, 6 of them (Perry NuclearPower Plant, Davis-Besse Nuclear Power Station,Beaver Valley Nuclear Power Station, HarrisonPower Station, Fort Martin Power Station,Pleasants Power Station, Bruce Mansfield PowerPlant, W.H. Sammis Power Plant) recycle their3

FirstEnergy Corporation CDP Water Security Questionnaire 2019 Wednesday,July 31, 2019non-contact cooling water; however, FirstEnergyfacilities are not located in areas that require useof recycled, brackish and/or produced water dueto supply constraints.W1.2(W1.2) Across all your operations, what proportion of the following water aspects areregularly measured and monitored?% ofPlease explainsites/facilities/operationsWater withdrawals – totalvolumes100%Total water withdrawals are measuredand/or monitored at all FirstEnergygeneration facilities, as required byNPDES permit and state waterwithdrawal permit/license requirements.Water withdrawals –volumes from waterstressed areasNot relevantFirstEnergy does not have facilitieslocated in high risk water stressed areas.Water withdrawals –volumes by source100%Water withdrawals by source aremeasured and/or monitored at allFirstEnergy generation facilities.Water withdrawals quality100%Total water withdrawal quality ismeasured and/or monitored at allFirstEnergy generation facilities, asrequired by NPDES permitrequirements.Water discharges – totalvolumes100%Total water discharges are measured andmonitored at all FirstEnergy generationfacilities.Water discharges –volumes by destination100%Water discharge volume by destinationare measured and monitored at allFirstEnergy generation facilities.Water discharges –volumes by treatmentmethod100%Water discharge volumes by treatmentmethod are measured and monitored atall FirstEnergy generation facilities.Water discharge quality –by standard effluentparameters100%Water discharge quality data aremeasured and monitored at allFirstEnergy generation facilities.Water discharge quality –temperature100%Water discharge quality data, includingtemperature, are measured and monitoredat all FirstEnergy generation facilities4

FirstEnergy Corporation CDP Water Security Questionnaire 2019 Wednesday,July 31, 2019Water consumption – totalvolume100%Water consumption at all FirstEnergygeneration facilities is calculated usingengineering estimates.Water recycled/reused100%Water recycling for non-contact coolingwater is measured/estimated at allFirstEnergy generation facilities withrecycling capabilitiesThe provision of fullyfunctioning, safelymanaged WASH servicesto all workers100%Facilities providing fully functioning WASHservices for all workers are measuredW-EU1.2a(W-EU1.2a) For your hydroelectric operations, what proportion of the following wateraspects are regularly measured and monitored?Fulfilment ofdownstreamenvironmentalflows% ofsites/facilities/operationsmeasured and monitoredPlease explain100%Yards Creek Generating Station providesdownstream flows of at least 0.875 cubic feet persecond to Yards Creek in fulfilment of its FERCpermit.Sediment loading Not relevantYards Creek Generating Station operates inaccordance with its FERC permit which does notprovide flow for sediment loadingOther, pleasespecifyYards Creek Generating Station providesecosystem services for endangered bats, timberrattlesnakes, various turtles, and Fowler's toads.Yards Creek Generating Station has partneredwith Environmental Consultation Services Inc. toensure that the reptiles and humans areprotected from each other.Not relevantW1.2b(W1.2b) What are the total volumes of water withdrawn, discharged, and consumedacross all your operations, and how do these volumes compare to the previousreporting year?Volume(megaliters/year)Comparison withprevious reportingyearPlease explain5

FirstEnergy Corporation CDP Water Security Questionnaire 2019 Wednesday,July 31, 2019Totalwithdrawals1,301,646LowerChanges in 2018 vs. 2017 reflectchanges in fleet operation, dispatch,and ownership.Totaldischarges1,152,347LowerChanges in 2018 vs. 2017 reflectchanges in fleet operation, dispatch,and ownership.Totalconsumption149,299LowerChanges in 2018 vs. 2017 reflectchanges in fleet operation, dispatch,and ownership.W1.2h(W1.2h) Provide total water withdrawal data by source.Relevance VolumeComparisonPlease explain(megaliters/year) with previousreporting yearFresh surface water,Relevantincluding rainwater, waterfrom wetlands, rivers,and lakes1,301,646LowerChanges in 2018 vs.2017 reflect changes infleet operation,dispatch, and,ownership.Brackish surfacewater/SeawaterNotrelevantBrackish surfacewater/seawater is notwithdrawn as part ofour operations.Groundwater –renewableNotrelevantGroundwater renewable as a sourceof withdrawal is notaccounted for as partof our operations.Groundwater – nonrenewableNotrelevantGroundwater - nonrenewable as a sourceof withdrawal is notaccounted for as partof our ced water as asource of withdrawal isnot accounted for aspart of our operations.Third party sourcesNotrelevantThird party sources asa source of withdrawalis not accounted for aspart of our operations.6

FirstEnergy Corporation CDP Water Security Questionnaire 2019 Wednesday,July 31, 2019W1.2i(W1.2i) Provide total water discharge data by destination.Relevance Volume(megaliters/year)Comparison with Please explainpreviousreporting yearFresh surfacewaterRelevantLowerBrackish surfacewater/seawaterNotrelevantDischarge to brackishsurface water/seawater isnot part of our operations.GroundwaterNotrelevantDischarge to groundwateris not part of scharge to third partydestinations is not part ofour operations.1,152,347Changes in 2018 vs. 2017reflect changes in fleetoperation, dispatch, and,ownership.W1.2j(W1.2j) What proportion of your total water use do you recycle or reuse?% recycled Comparison with Please explainand reused previous reportingyearRow 76-99%1About the sameSeven of the nine steam electric FirstEnergy generationfacilities, (Perry, Davis-Besse, Beaver Valley, Mansfield,Pleasants, Fort Martin, and Harrison) use closed cyclecooling that can reduce the flows 80 to 90 percent for afacilityW-EU1.3(W-EU1.3) Do you calculate water intensity for your electricity generation activities?No, and we have no plans to do so in the next two yearsW1.4(W1.4) Do you engage with your value chain on water-related issues?No, we do not engage on water with our value chain7

FirstEnergy Corporation CDP Water Security Questionnaire 2019 Wednesday,July 31, 2019W1.4d(W1.4d) Why do you not engage with any stages of your value chain on water-relatedissues and what are your plans?Primary reason Please explainRow Important but not FirstEnergy is a forward-thinking electric utility committed to making1an immediatecustomers’ lives brighter and the environment better. As such, FirstEnergybusiness priority regularly engages with our customers and other stakeholders regardingwater and ecosystems within our territory. In just the second quarter 2018,FirstEnergy provided 8,000 in grants to the American Littoral Society forcoastal enhancements and Hawk Mountain Sanctuary Association forenvironmental education. FirstEnergy also offers a Speakers Bureau, free ofcharge, to civic organizations, chambers of commerce, and consumergroups to discuss issues, such as energy and the environment. Suchcommunity and stakeholder initiatives and engagement are guided byFirstEnergy's mission statement and Corporate Responsibility Initiatives.W2. Business impactsW2.1(W2.1) Has your organization experienced any detrimental water-related impacts?YesW2.1a(W2.1a) Describe the water-related detrimental impacts experienced by yourorganization, your response, and total financial impact.Country/RegionUnited States of AmericaRiver basinMississippi RiverType of impact driverRegulatoryPrimary impact driverRegulation of discharge quality/volumesPrimary impactImpact on company assetsDescription of impact8

FirstEnergy Corporation CDP Water Security Questionnaire 2019 Wednesday,July 31, 2019On September 30, 2015, USEPA finalized a rule revising the regulations for the SteamElectric Power Generating category. The rule sets strict limits on the discharge ofpollutants in flue gas desulfurization waste water and prohibits the discharge of coal ashtransport water. The new requirements directly affect FirstEnergy generation facilitiesand compliance costs will be in the millions of dollars. Parts of the new ELGs are underreconsideration. The reconsideration provides a period of time that there is uncertaintyto the company's strategy for complying with the rule. EPA's regulatory calendar statesa proposed rule revision in June 2019 and a final rule in August 2020.Primary responseComply with local regulatory requirementsTotal financial impactDescription of responseDepending on the outcome of appeals and how any final rules are ultimatelyimplemented, FirstEnergy will comply with the requirements.W2.2(W2.2) In the reporting year, was your organization subject to any fines, enforcementorders, and/or other penalties for water-related regulatory violations?NoW3. ProceduresW-EU3.1(W-EU3.1) How does your organization identify and classify potential water pollutantsassociated with your business activities in the electric utilities sector that could havea detrimental impact on water ecosystems or human health?FirstEnergy generation facilities are regulated under various federal, state, and local waterquality regulations, the majority of which are the result of the Clean Water Act and itsamendments.FirstEnergy monitors, identifies, and classifies potential pollutant by compliance with thosewater quality regulations.W-EU3.1a(W-EU3.1a) Describe how your organization minimizes the adverse impacts ofpotential water pollutants associated with your activities in the electric utilities sectoron water ecosystems or human health.PotentialwaterpollutantDescription of waterpollutant and potentialimpactsManagementproceduresPlease explain9

FirstEnergy Corporation CDP Water Security Questionnaire 2019 Wednesday,July 31, 2019CoalIn April 2015, EPA finalizedcombustion regulations for CCRs. EPAresidualshas published with the CCRregulations, potential waterpollutant and operationalimpacts from CCRs.Compliance witheffluent qualitystandardsThermalpollutionCompliance witheffluent qualitystandardsIn 2018, FirstEnergy ownedand operated 8 thermalelectric power plants (PerryNuclear Power Plant, DavisBesse Nuclear PowerStation, Beaver ValleyNuclear Power Station,Harrison Power Station,Fort Martin Power Station,Pleasants Power Station,Bruce Mansfield PowerPlant, W.H. Sammis PowerPlant). Non-contact coolingwater is used at theseplants and is inherent to thethermal electric productionprocess. As such, all thethermal electric powerplants have obtained 316(a)variances for heatedeffluent discharges.While certain provisions of theApril 2015 CCR rule are underreconsideration, FirstEnergyCommunity/stakeholder intends to comply with the CCRrule, as appropriate.engagementEmergencypreparednessThe potential environmentalimpacts have been reviewedand studied in the NPDESCommunity/stakeholder permit supportingdocumentation and 316(a)engagementstudies. The results of thesupporting documentation andstudies are permit limits whichthe facilities complies with.FirstEnergy voluntarilyconducts ecological researchon the Ohio River through apartnership with the Ohio RiverEcological Research Program(ORERP).W3.3(W3.3) Does your organization undertake a water-related risk assessment?Yes, water-related risks are assessedW3.3a(W3.3a) Select the options that best describe your procedures for identifying andassessing water-related risks.Direct operationsCoverageFullRisk assessment procedureWater risks are assessed as part of an enterprise risk management framework10

FirstEnergy Corporation CDP Water Security Questionnaire 2019 Wednesday,July 31, 2019Frequency of assessmentSix-monthly or more frequentlyHow far into the future are risks considered?3 to 6 yearsType of tools and methods usedTools on the marketEnterprise Risk ManagementDatabasesOtherTools and methods usedWRI AqueductCOSO Enterprise Risk Management FrameworkRegional government databasesInternal company methodsOther, please specifyPENTOXSD, Cormix, as appropriateCommentFirstEnergy has a formal, comprehensive Enterprise-Wide Risk Management (EWRM)program in place to evaluate water risks on an as needed basis. Plant water quality isfrequently assessed under National Pollutant Discharge Elimination System (NPDES)permit conditions. Also, several of FirstEnergy's Ohio River facilities are assessedannually through our participation with the Electric Power Research Institute (EPRI),Ohio River Ecological Research Program (ORERP), and/or the Ohio River Valley WaterSanitation Commission (ORSANCO).Supply chainCoverageNoneCommentOther stages of the value chainCoveragePartialRisk assessment procedureWater risks are assessed as part of an enterprise risk management frameworkFrequency of assessmentAnnuallyHow far into the future are risks considered?3 to 6 years11

FirstEnergy Corporation CDP Water Security Questionnaire 2019 Wednesday,July 31, 2019Type of tools and methods usedDatabasesOtherTools and methods usedRegional government databasesInternal company methodsCommentFirstEnergy has developed an extensive internal emergency response organization. Assuch, an incident command structure is employed and drills are conducted, at least,annually. We participate in working groups, training opportunities, and conferences at alllevels of the public and private sectors to ensure readiness, build relationships, and stayabreast of technological advances.W3.3b(W3.3b) Which of the following contextual issues are considered in yourorganization’s water-related risk assessments?Relevance &inclusionPlease explainWater availability at abasin/catchment levelRelevant,sometimesincludedThese issues are relevant and included as situationsarise.Water quality at abasin/catchment levelRelevant,sometimesincludedThese issues are relevant and included as situationsarise.Stakeholder conflictsRelevant,concerning water resources sometimesat a basin/catchment levelincludedFirstEnergy works to minimize the environmentalimpact of our generating plants and other facilities.Our sustainability efforts reflect our commitment tocreating lasting value in the communities where welive and work.Implications of water onyour key These issues are relevant and included as situationsarise.Water-related regulatoryframeworksRelevant,The Company works and complies in the frameworkalways included of the Clean Water Act and actively evaluates theevolving regulatory framework.Status of ecosystems andhabitatsRelevant,All relevant water quality standards, Endangeredalways included Species Act, and wetland impacts are evaluated assituations arise to minimize ecosystem and habitatissues.12

FirstEnergy Corporation CDP Water Security Questionnaire 2019 Wednesday,July 31, 2019Access to fully-functioning,safely managed WASHservices for all employeesRelevant,The Company works to ensure that all employeesalways included have access to WASH servicesOther contextual issues,please specifyNot relevant,explanationprovidedFirstEner

Jul 31, 2019 · FirstEnergy Corporation CDP Water Security Questionnaire 2019 Wednesday, July 31, 2019 1 Welcome to your CDP Water Security Questionnaire 2019 W0. Introduction W0.1 (W0.1) Give a general description of and introduction to your organization. Headquartered in Akron, Ohio, FirstEnergy

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